AFTAP Fun

[JAY21]

So if I understand the rules correctly, if we don't have the AFTAP done by 12/31/07 for 2007 then 1/1/08 we are deemed to have a 60% AFTAP for contingent events and amendment purposes, but under a transitional rule don't have benefit restrictions (e.g., lump sums) until 4/1/08 (calendar plan assumed). So for those of us stubborn or slow to change to BOY vals, with little hope of getting all 2007 vals done for AFTAP purposes by 12/31/07, are we SOL ?? Any friends out there sharing these woes ?? Do we still have hope for divine intervention by IRS for EOY vals that might relax these rules and/or a Congressional delay on these rules ? Misery loves company, so I'm looking for friends out there if anyone is in this situation too, and if so, what if anything are you doing about this at this point ? Maybe there isn't much to be done except for whatever few frantic Vals/AFTAP could get done by 12/31/07.

[ak2ary]

I am holding out hope for some intervention...although I hesitate to characterize it a divine

[rcline46]

For (nearly) all purposes, a 12/31 val is equivalent to a 1/1 val (I know, new entrants, but accrued benefits are the same for actives). Assets don't change. I would therefore equ/ivoc/ate to say use the 12/31/06 val as if it were a 1/1/07 val. And yes I did say equivocate and not equate.

[tymesup]

We're working on the 1/1/07 vals first. By the time we are done, we are hoping that there'll be some relief for EOYs.

We are also changing the corporate mascot to the ostrich.

[JanetM]

Prarie Dog would be better mascot. Or maybe a mole.

[JAY21]

rcline46, I like your idea. I assume we'd have to change the val date then to BOY (1/1/07) to support the near identical values from the previous 12/31/06 EOY val, right ? Which I'm not necessarily opposed to if needed.

[Andy the Actuary]

For (nearly) all purposes, a 12/31 val is equivalent to a 1/1 val (I know, new entrants, but accrued benefits are the same for actives). Assets don't change. I would therefore equ/ivoc/ate to say use the 12/31/06 val as if it were a 1/1/07 val. And yes I did say equivocate and not equate.

Note that accrued benefit could change from 12/31 to 1/1 owing to increase in the 401(a)(17) and 415(b) limits.

[Guest saeissler]

I too am using the "wait and see" technique. Optimist that I am, I believe that since we are allowed, as small plans, to have valuation dates other than 1/1. there will have to be regulations to back that up.